According the BLM’s Instructional Memorandum on this issue, “additional costs will result from implementing this policy” [of discontinuing CEs].

Karen Budd Falen of the Budd-Falen Law Offices in Cheyenne, Wyoming is concerned about the additional cost. Ms. Falen states that “The BLM admits that it is woefully behind completing its NEPA compliance paperwork, even on the smallest of permits and even when the rangeland conditions are in excellent condition.” Ms. Falen’s concern is that if the NEPA documentation not completed by the end of the livestock grazing term, livestock grazing could be eliminated.